IRS Releases Proposed Foreign Tax Credit Regulations
Posted on Nov 29, 2018 in International Tax, News
On November 28, the IRS released proposed regulations (REG-105600-18) concerning the treatment of foreign tax credits and related issues taking into account the changes made by under the Tax Cuts and Jobs Act (TCJA). Foreign tax provisions under the TCJA modified the method for calculating taxable income for purposes of the foreign tax credit limitation; added two additional foreign...
House Republicans Release Tax Package
Posted on Nov 28, 2018 in News, Tax Accounting
House Republicans released a 297 page tax bill on the evening of November 26, with the possibility of voting on the proposed bill as soon as this week. The legislation includes a number of “extenders,” which would renew certain tax provisions set to expire; tax breaks for smaller businesses; and technical corrections to the Tax Cuts and Jobs Act (TCJA) passed in 2017. The five...
IRS Releases Business Interest Expense Proposed Regulations
Posted on Nov 27, 2018 in News, Tax Accounting
The IRS has released proposed regulations (REG-106089-18) concerning the business interest expense deduction limits applied to certain taxpayers. As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) generally places a limit on the amount of deductible business interest expenses in a current taxable year. The proposed regulations, released on November 26, provide rules for...
OIRA Receives Section 267A Regulations for Review
Posted on Nov 16, 2018 in International Tax
The IRS on November 13th submitted its proposed section 267A anti-hybrid regulations to the Office of Information and Regulatory Affairs for expedited review. Section 267A of the Tax Cuts and Jobs Act, eliminates deductions for any “disqualified related party amount” paid or accrued through a related hybrid entity or transaction. The regulations are expected to address such issues as...
Single Entity Can Apply 199A De Minimis Rule Multiple Times, According to IRS Official
Posted on Nov 15, 2018 in News, Pass-through Taxation
Speaking at the American Institute of CPAs Fall Tax Division Meeting in Washington, D.C. on November 14, IRS associate chief counsel Holly Porter stated that the section 199A de minimis test applied to identify specified service businesses could apply multiple times for the same entity if separate businesses are being operated. Enacted by the Tax Cuts and Jobs Act (TCJA), section 199A...
Eversheds Sutherland Seattle CPE Day – Navigating The Changing World of Tax – Day 2, November 7, 2018
Posted on Nov 15, 2018 in Presentations, Uncategorized
Please view our presentations from day 2 of our Seattle CPE Day on federal and international tax planning. Hard Knock Life: The New Worldwide Territoriality and the Continuing Significance of the Foreign Tax Credit in the US – Speakers, Randy Buchanan and Robb Chase On to the Next One: The Increasing Importance of Destination in Tax Regimes – Speakers, Michele Borens, Randy...
Eversheds Sutherland Seattle CPE Day – Navigating The Changing World of Tax – Day 1, November 6, 2018
Posted on Nov 15, 2018 in Presentations, Uncategorized
Please view our presentations from our Seattle CPE Day on federal and international tax planning. 99 Problems: Planning in a Time of Tax Uncertainty – Speakers, Robb Chase, Randy Buchanan, Mary Monahan and Stefanie Wood Empire State of Mind: International M&A Post Tax Reform – Speakers, Daniel Nicholas and Jed Rogers Can’t Knock the Hustle: The Implications of...
Eversheds Sutherland Year-End Tax Seminar – Navigating the Changing World of Tax, November 14, 2018, Philadelphia, PA
Posted on Nov 14, 2018 in Presentations, Uncategorized
Please view our presentations from Eversheds Sutherland’s year-end tax seminar on federal and international tax planning. 99 Problems: Addressing Risk in a Time of Tax Uncertainty – Speakers, Ellen McElroy, Karl Zeswitz and Michael Resnick Can’t Knock the Hustle: The Implications of International Reforms for Audit and Controversy – Speakers, Mary Monahan and Robb...
IRS to Consider Changing Section 199A Aggregation Rules Based on Comments
Posted on Nov 13, 2018 in Pass-through Taxation
IRS official Benjamin Weaver stated that the IRS is open to changing the aggregation rules set forth in the proposed section 199A pass-through deduction regulations since they are not “statutorily derived.” Weaver stated that the IRS has received numerous comments on the proposed regulations, particularly on the requirement that attributes of multiple businesses be aggregated at the...
IRS Releases Priority Guidance Plan for 2018-2019
Posted on Nov 9, 2018 in Individual Taxation, International Tax, Pass-through Taxation, Tax Accounting
On November 8, the IRS and Treasury Department released their priority guidance plan (PGP) for 2018-2019, which includes a number of projects concerning the implementation of the Tax Cuts and Jobs Act. Planned projects include finalizing regulations under sections 199A (the 20% deduction for qualifying business income) and 951A (global intangible low-taxed income) and issuing...
BEAT Regulations submitted to OMB
Posted on Nov 7, 2018 in International Tax
The IRS has submitted its proposed base erosion and anti-abuse tax (BEAT) regulations to the U.S. Office of Management and Budget for review. Under section 59A of the Tax Cuts and Jobs Act (TCJA), the BEAT is an alternative minimum tax on income with deductions for payments between U.S. corporations and their foreign affiliates added back, which is designed to limit shifting of...
OMB Receives Proposed Foreign Tax Credit Regs for Review
Posted on Nov 7, 2018 in International Tax
The Office of Management and Budget (OMB) received proposed foreign tax regulations for review on November 7. The regulations include guidance on allocation of expenses to the section 951A Global Intangible Low-Taxed Income (GILTI) basket for purposes of determining the foreign tax credit limitation, as well as transition rules for excess foreign tax credit carryforwards. The...